RCRA Facility Investigation (RFI)

1. Purpose

The purpose of this RCRA Facility Investigation (RFI) is to determine the nature and extent of releases of hazardous waste or constituents from regulated units, solid waste management units (SWMUs), and areas of concern (AOCs) at the Facility, and to gather all necessary data to support the Corrective Measures Study. The Respondent shall furnish all personnel, materials, and services necessary for, or incidental to, performing the RFI at the Facility. EPA/TNRCC/CSSA shall develop a process to determine the level of investigation required for each site. In order to expedite the remediation of the most contaminated sites first, a phased RFI approach will be utilized. A site that is determined to be an AOC will be investigated. If any AOC is identified as having chemicals of concern that have been released into the environment, it shall be added to the RFI process.

2. Scope

The RFI consists of seven tasks:

1. Task I: Preliminary Report: Description of Current Conditions

1. Facility Background

2. Nature and Extent of Contamination

3. Pre-Investigation Evaluation of Corrective Measure Technologies

2. Task II: RFI Workplan

1. Project Management Plan

2. Data Collection Quality Assurance Plan

3. Data Management Plan

4. Health and Safety Plan

5. Community Relations Plan

3. Task III: Facility Investigation

1. Environmental Setting

2. Source Characterization

3. Contamination Characterization

4. Potential Receptor Identification

4. Task IV: Human Health and Ecological Risk Assessment

5. Task V: Investigation Analysis

6. Task VI: Treatability Studies

7. Task VII: Progress Reports

B.1. Task I - Preliminary Report: Description of Current Conditions

The Respondent shall submit a Preliminary Report: Description of Current Conditions (DCC) to EPA for approval or modification and approval, in accordance with Section VI.2 of the Order. The DCC Report shall provide the information as set forth below. The data gathered during any previous investigations or inspections and other relevant data shall be included. In providing the information requested below, Respondent shall provide either a written response or a reference to existing documentation which addresses the requested information. Respondent may submit the CSSA Environmental Encyclopedia as the DCC, as long as the information set forth below is included in the CSSA Environmental Encyclopedia.

1. Facility Background

The Respondent's DCC Report shall include a summary of the regional location, pertinent boundary features, general Facility physiography, hydrogeology, and historical use of the Facility for the treatment, storage or disposal of solid and hazardous waste. The Respondent's report shall include, but not be limited to, the following:

1. Map(s) depicting the following:

1. General geographic location;

2. Property lines, with the owners of all adjacent property clearly indicated, and all land previously owned and/or used by the Facility around what has been designated as the Facility;

3. Topography (with a contour interval of five (5) or ten (10) feet and an approximate scale of 3/4 inch = 100 feet), showing waterways, all wetlands, floodplains, surface water features, drainage patterns;

4. All tanks, past or present, buildings, utilities, paved areas, easements, rights-of-way, and other features;

5. All solid or hazardous waste treatment, storage or disposal areas active after November 19, 1980;

6. All known past solid or hazardous waste treatment, storage or disposal areas regardless of whether they were active on November 19, 1980;

7. All known past and present underground product and waste tanks or piping;

8. Surrounding land uses (residential, commercial, agricultural, recreational);

9. The location of all production and ground water monitoring wells. These wells shall be clearly labeled with ground and top of casing elevations included; and

10. The location of all wastewater and storm water outfalls used by the Facility.

All maps shall be of sufficient detail and accuracy to locate and report all past, current and future work performed at the Facility;

2. A history and description of ownership and operation, solid and hazardous waste generation, treatment, storage and disposal activities at the Facility;

3. Approximate dates or periods of all known past product and waste spills, identification of the materials spilled, the amount spilled, the location where spilled, and a description of the response actions conducted (local, State, or Federal response units or private parties), including copies of all inspection reports and technical reports generated as a result of the response; and

4. A summary of past permits requested and/or received, any State or Federal environmental enforcement actions taken against the Facility, the resolution thereof, and a list of environmental studies performed for the Facility.

2. Nature and Extent of Contamination

The Respondent shall include in the Preliminary Report the existing information on the nature and extent of contamination.

1. The Respondent's DCC Report shall include a summary of all possible source areas of contamination. This, at a minimum, should include all regulated units, solid waste management units, spill areas, and other suspected source areas of contamination. For each area, the Respondent shall identify the following:

1. Location of unit/area (which shall be depicted on a Facility map);

2. Quantities of solid and hazardous wastes in the area;

3. Hazardous waste or constituents, to the extent known, in the area; and

4. Identification of areas where additional information is necessary.

2. The Respondent shall include in the DCC Report an assessment and description of the existing degree and extent of contamination. This should include, but not be limited to, the following:

1. Available monitoring data and qualitative information on locations and levels of contamination at the Facility;

2. All potential migration pathways, including information on geology, pedology, hydrogeology, physiography, hydrology, water quality, meteorology, and air quality; and

3. The potential impact(s) on human health and the environment, including demography, ground water and surface water use, and land use.

3. Pre-Investigation Evaluation of Corrective Measure Technologies

Respondent shall include in the DCC Report an identification of site criteria that may influence the selection of corrective measure technologies that may be used on-site or off-site for the containment, treatment, remediation, and/or disposal of contamination at or nearby the Facility. Respondent shall also identify any field, laboratory, bench or pilot scale data that need to be collected in the facility investigation to facilitate the evaluation and selection of the final corrective measure or measures (e.g., compatibility of waste and construction materials, information to evaluate effectiveness, treatability of wastes, etc.).

B.2. Task II - RFI Workplan Requirements

The Respondent shall prepare a Final RFI Workplan in accordance with Section VI.2. of the Order. The RFI Workplan shall include the development of several distinct plans, which shall be prepared concurrently. The RFI Workplan as approved or modified by EPA shall become the Final RFI Workplan. During the RFI, it may be necessary to revise the Final RFI Workplan to accommodate a Facility specific situation. The RFI Workplan shall include the following:

1. Project Management Plan (Work Plan)

The Respondent shall prepare a Project Management Plan, which will include a discussion of the technical approach, schedules, budget, and necessary personnel. The technical approach shall include the rationale for investigation of each media (soil, ground water, surface water, soil gas, and air) and a description of each area of concern which may have contamination from Facility activities. The technical approach shall address all the requirements set forth in Task III of this Corrective Action Plan. The Project Management Plan shall also document the overall management approach to the RFI.

2. Data Collection Quality Assurance Plan (Field Sampling Plan)

The Respondent shall prepare a Data Collection Quality Assurance Plan to document all monitoring procedures, including: sampling, field measurements, and sample analysis performed during the investigation to characterize the environmental setting, source, and contamination, so as to ensure that all information, data and resulting decisions are technically sound, statistically valid, and properly documented.

1. Data Collection Strategy

The Data Collection Strategy shall include, but not be limited to, the following:

1. Description of the intended uses for the data, and the necessary level of precision and accuracy for these intended uses;

2. Description of methods and procedures to be used to assess the precision, accuracy and completeness of the measurement data;

3. Description of the methodology used to assure that the data accurately and precisely represent the characteristics of a population, parameter variations at a sampling point, and process conditions or environmental conditions.

Examples of factors which shall be considered and discussed include:

1. Environmental conditions at the time of sampling;

2. Number of sampling points;

3. Representativeness of selected media; and

4. Representativeness of selected analytical parameters.

4. Description of the measures to be taken to assure that the following data sets can be compared to each other:

1. RFI data generated by the Respondent;

2. RFI data generated by parties other than the Respondent;

3. Data previously generated by Respondent or Respondent's agents.

4. Data previously generated by parties other than the Respondent.

5. Details relating to the schedule and information to be provided in quality assurance reports. The reports shall include but not be limited to:

1. Periodic assessment of measurement data accuracy, precision, and completeness;

2. Results of performance audits, including whatever corrective actions are necessary as a result of audits and re-audits;

3. Results of system audits; and

4. Significant quality assurance problems and recommended solutions;

2. Sampling

The Sampling Strategy shall discuss:

1. Selecting appropriate sampling locations, depths, etc.;

2. Determining a statistically sufficient number of sampling sites;

3. Measuring all necessary ancillary data;

4. Determining conditions under which sampling will be conducted;

5. Determining which media are to be sampled (e.g., ground water, air, soil, sediment, etc.);

6. Determining which parameters are to be measured and where;

7. Selecting the frequency of sampling and length of sampling period;

8. Selecting the types of sample (e.g., composites vs. grabs) and number of samples to be collected;

9. Documenting field sampling operations and procedures, including;

1. Documentation of procedures for preparation of reagents or supplies which become an integral part of the sample (e.g., filters, and adsorbing reagents);

2. Procedures and forms for recording the exact location and specific considerations associated with sample acquisition;

3. Documentation of specific sample preservation method;

4. Calibration of field devices;

5. Collection of replicate samples;

6. Potential interferences present at the Facility;

7. Construction materials and techniques, associated with monitoring wells and piezometers;

8. Field equipment listing and sample containers;

9. Sampling order; and

10. Decontamination procedures.

10. Selecting appropriate sample containers;

11. Sample preservation; and

12. Chain-of-custody, including:

1. Standardized field tracking reporting forms to establish sample custody in the field prior to shipment; and

2. Pre-prepared sample labels containing all information necessary for effective sample tracking.

3. Field Measurements

The Field Measurements Strategy shall discuss:

1. Selecting appropriate field measurement locations, depths, etc.;

2. Providing a statistically sufficient number of field measurements;

3. Measuring all necessary ancillary data;

4. Determining conditions under which field measurement should be conducted;

5. Determining which media are to be addressed by appropriate field measurements (e.g., ground water, air, soil, sediment, etc.);

6. Determining which parameters are to be measured and where;

7. Selecting the frequency of field measurement and length of field measurements period; and

8. Documenting field measurement operations and procedures, including:

1. Procedures and forms for recording raw data and the exact location, time, and Facility-specific considerations associated with the data acquisition;

2. Calibration of field devices;

3. Collection of replicate measurements;

4. Potential interferences present at the Facility;

5. Construction materials and techniques associated with monitoring wells and piezometers used to collect field data;

6. Field equipment listing;

7. Order in which field measurements were made; and

8. Decontamination procedures.

4. Contaminated Material Disposal

All waste material and material contaminated with hazardous constituents generated by activities required in the RFI shall be disposed of in accordance with all State and Federal regulations.

5. Sample Analysis

The Sample Analysis Strategy shall specify the following:

1. Chain-of-custody procedures, including:

1. Identification of a responsible party to act as sample custodian at the laboratory facility authorized to sign for incoming field samples, obtain documents of shipment, and verify the data entered onto the sample custody records;

2. Provision for a laboratory sample custody log consisting of serially numbered standard lab-tracking report sheets; and

3. Specification of laboratory sample custody procedures for sample handling, storage, and disbursement for analysis.

2. Sample storage procedures and holding times;

3. Sample preparation methods;

4. Analytical procedures, including:

1. Scope and application of the procedure;

2. Sample matrix;

3. Potential interferences;

4. Precision and accuracy of the methodology;

5. Method detection limits;

6. Calibration procedures and frequency;

7. Data reduction, validation and reporting;

8. Internal quality control checks, laboratory performance and systems audits and frequency, to be conducted annually during the life of an analytical services subcontract by Parsons or other contractor working for Respondent, including:

1. Method blank(s);

2. Laboratory control sample(s);

3. Calibration check sample(s);

4. Replicate sample(s);

5. Matrix-spiked sample(s);

6. "Blind" quality control sample(s);

9. Preventive maintenance procedures and schedules;

10. Corrective action (for laboratory problems); and

11. Turnaround time.

3. Data Management Plan (Quality Assurance Project Plan)

The Respondent shall develop and implement a Data Management Plan to document and track investigation data and results. This plan shall identify and set up data documentation materials and procedures, project file requirements, and project-related progress reporting procedures and documents. The plan shall also provide the format to be used to present the raw data and conclusions of the RFI.

1. Data Record

The data record shall include, but not be limited to, the following:

1. Unique sample or field measurement code;

2. Sampling or field measurement location and sample or measurement type;

3. Sampling or field measurement raw data;

4. Laboratory analysis ID number;

5. Property or component measured; and

6. Result of analysis (e.g., concentration).

2. Tabular Displays

The following data shall be presented in tabular displays:

1. Unsorted (raw) data;

2. Results for each medium, or for each constituent monitored;

3. Data reduction for statistical analysis;

4. Sorting of data by potential stratification factors (e.g., location, soil layer, topography); and

5. Summary data.

3. Graphical Displays

The following data shall be presented in graphical formats (e.g., bar graphs, line graphs, area or plan maps, isopleth plots, cross-sectional plots or transects, three dimensional graphs, etc.):

1. Display sampling locations and sampling grids;

2. Boundaries of sampling areas, and areas where more sampling is required;

3. Levels of contamination at each sampling location;

4. Geographical extent of contamination;

5. Display contamination levels, averages, and maxima;

6. Illustrate changes in concentration in relation to distance from the source, time, depth or other parameters; and

7. Indicate features affecting intramedia transport and show potential receptors; and

8. Illustrate the structural geology in the area of the Facility, including detailed structural geology of the Facility.

4. Health and Safety Plan

The Respondent shall prepare and implement a Health and Safety Plan for RFI activities at the Facility.

1. Major elements of the Health and Safety Plan shall include, but not be limited to, the following:

1. Facility description, including availability of resources such as roads, water supply, electricity and telephone service;

2. Describe the known hazards and evaluate the risks associated with each activity conducted, including, but not limited to on and off-site exposure to contaminants during the implementation of interim measures at the Facility;

3. List key personnel and alternates responsible for site safety, response operations, and for protection of public health;

4. Delineate work areas;

5. Describe levels of protection to be worn by personnel in work area;

6. Establish procedures to control site access;

7. Describe decontamination procedures for personnel and equipment;

8. Establish site emergency procedures;

9. Address emergency medical procedures for injuries and toxicological problems;

10. Describe requirements for an environmental surveillance program;

11. Specify any routine and special training required for responders; and

12. Establish procedures for protecting workers from weather-related problems.

2. The Health and Safety Plan shall be consistent with:

1. NIOSH Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities (1985);

2. EPA Order 1440.1 - Respiratory Protection;

3. EPA Order 1440.3 - Health and Safety Requirements for Employees engaged in Field Activities;

4. Facility Contingency Plan;

5. EPA Standard Operating Safety Guide (1984);

6. OSHA regulations particularly in 29 CFR 1910 and 1926;

7. State and local regulations; and

8. Other EPA guidance as provided.

5. Community Relations Plan

Respondent shall prepare a Community Relations Plan which includes a description of the site background, history of community involvement at the site, community relations strategies, a schedule of community relations activities, a list of contacts, local officials, and interested parties. Respondent shall coordinate public relations activities with the EPA Project Manager. Respondent shall never appear to represent or speak for EPA before the public, other governmental officials, or the media.

B.3. Task III - Facility Investigation

The Respondent shall conduct those investigations necessary to: characterize the Facility (Environmental Setting); define the source of contamination (Source Characterization); define the degree and extent of contamination (Contamination Characterization); and identify actual or potential receptors.

The investigations should result in data of adequate technical quality to support the development and evaluation of the alternatives during the Corrective Measures Study.

The Facility investigation activities shall be conducted in accordance with the RFI Workplan. All sampling and analyses shall be conducted in accordance with the Data Collection Quality Assurance Plan.

At the conclusion of the Facility investigations, the Respondent shall prepare and submit to EPA for review and approval an RFI Report, which shall contain an analysis and a summary of all Facility investigations implemented pursuant to the requirements of this Task III. EPA will approve or modify and approve the RFI Report.

1. Environmental Setting

The Respondent shall collect information to supplement and verify existing information on the environmental setting at the Facility. The Respondent shall characterize the following:

1. Hydrogeology

The Respondent shall prepare a report evaluating hydrogeologic conditions at the Facility. This report shall be included in the RFI Report and shall provide the following information:

1. A description of the regional and Facility specific geologic and hydrogeologic characteristics affecting ground water flow beneath the Facility, including:

1. Regional and Facility specific stratigraphy;

2. Regional structural geology;

3. Depositional history;

4. Identification and characterization of areas and amounts of recharge and discharge;

5. Regional and Facility specific ground water flow patterns;

6. Seasonal variation in ground water flow patterns.

2. An analysis of any topographic features that might influence the ground water flow system;

3. Based on field data, tests, (gamma and neutron logging of existing and new wells, piezometers and borings) and cores, a representative and accurate classification and description of the hydrogeologic units which may be part of the migration pathways at the Facility (i.e., the aquifers and any intervening saturated and unsaturated units), including:

1. Hydraulic conductivity and porosity (total and effective);

2. Lithology, grain size, sorting, degree of cementation;

3. An interpretation of hydraulic interconnections between saturated zones; and

4. The attenuation capacity and mechanisms of the natural earth materials (e.g., ion exchange capacity, organic carbon content, mineral content etc.).

4. Based on field studies and cores, structural geology and hydrogeologic cross sections showing the extent (depth, thickness, lateral extent) of hydrogeologic units which may be part of the migration pathways identifying:

1. Sand and gravel deposits in unconsolidated deposits;

2. Zones of fracturing or channeling in consolidated or unconsolidated deposits; and

3. Zones of higher permeability or lower permeability that might direct and restrict the flow of contaminants;

5. Based on data obtained from ground water monitoring wells and piezometers installed upgradient and downgradient of the potential contaminant source, a representative description of water level or fluid pressure monitoring including:

1. Water-level contour and/or potentiometric maps;

2. Hydrologic cross sections showing vertical gradients;

3. The flow system, including the vertical and horizontal components of flow;

4. Any temporal changes in hydraulic gradients, due to seasonal influences; and

5. Create flow net maps using well cluster data.

6. A description of manmade influences that may affect the hydrogeology of the Facility, identifying:

1. Active and inactive local water-supply and production wells with an approximate schedule of pumping; and

2. Manmade hydraulic structures (pipelines, french drains, ditches, etc.).

2. Soils

The Respondent shall conduct a program to characterize the geologic units above the water table in the vicinity of the contaminant release(s). Such characterization may include, as appropriate, but not be limited to, the following information:

1. USCS soil classification;

2. Soil profile, including ASTM classification of soils;

3. Directional relative permeability;

4. Bulk density;

5. Soil pH;

6. Particle size distribution;

7. Moisture content;

8. Infiltration (field test);

9. Storage capacity;

10. Mineral content; and

11. Soil conductivity.

3. Surface Water and Sediment

The Respondent shall conduct a program to characterize any marshes, creeks, wetland areas, or ditches surrounding and crossing the Facility, as appropriate. Such characterization shall include, but not be limited to, the following activities and information:

1. Description of the temporal and permanent surface water bodies including:

1. For all local wetland areas, temporal surface water bodies, and channels: location, elevation, flow, velocity, depth, width, seasonal fluctuations, and flooding tendencies (i.e., 100 year event);

2. Drainage patterns; and

3. Evapotranspiration rates.

2. Description of the chemistry of surface water and sediments. This includes determining the pH, total dissolved solids, total suspended solids, biochemical oxygen demand, alkalinity, conductivity, dissolved oxygen profiles, nutrients, chemical oxygen demand, total organic carbon, and specific contaminant concentrations, as proposed by the Respondent and approved by EPA;

3. Description of sediment characteristics including:

1. Deposition area;

2. Thickness profile; and

3. Physical parameters (e.g., grain size, density, ion exchange capacity, etc.).

2. Source Characterization

Respondent shall document and quantify in the RFI Report the following specific characteristics to the extent known or ascertainable at all known source areas of hazardous wastes and/or hazardous constituents subsequent to November 1980 and to the extent known or ascertainable for periods prior thereto:

1. Source Areas

2. Unit/Disposal Area Characteristics:

1. Location of unit/disposal area;

2. Type of unit/disposal area;

3. Design features;

4. Operating practices (past and present);

5. Period of operation;

6. Age of unit/disposal area;

7. General physical conditions; and

8. Method used to close the unit/disposal area.

3. Waste Characteristics:

1. Type of waste placed in each unit;

1. Hazardous classification (e.g., flammable, reactive, corrosive, oxidizing or reducing agent);

2. Quantity; and

3. Chemical composition.

2. Physical and chemical characteristics of the wastes;

1. Physical form (solid, liquid, gas);

2. Physical description (e.g., powder, oily sludge);

3. Temperature;

4. pH;

5. General chemical class (e.g., acid, base, solvent);

6. Molecular weight;

7. Density;

8. Boiling point;

9. Viscosity;

10. Solubility in water;

11. Cohesiveness of the waste; and

12. Vapor pressure.

3. Migration and dispersal characteristics of the waste;

1. Sorption;

2. Biodegradability, bioconcentration, biotransformation;

3. Photodegradation rates;

4. Hydrolysis rates; and

5. Chemical transformations.

The Respondent shall document the procedures used in making the above determinations.

3. Contamination Characterization

The Respondent shall collect analytical data on ground water, soils, surface water and sediment contamination in the vicinity of the Facility and include said data in the RFI Report. These data shall be sufficient to define the extent, origin, direction, and rate of movement of contaminant plumes. Data shall include time and location of sampling, media sampled, concentrations found, and conditions during sampling, and the identity of the individuals performing the sampling and analysis. The Respondent shall prepare for the RFI Report maps that indicate the extent of contamination within all media. The Respondent shall address the following types of contamination at the Facility:

1. Ground Water Contamination

Respondent shall characterize the vertical and horizontal extent of the ground water contamination plume. This characterization must include monitoring wells completed at various depths dependent upon hydrogeological conditions and contaminant characteristics. Characterization of the plume beyond Facility boundaries shall be conducted with a program utilizing present monitoring wells, additional wells and soil gas testing. This investigation shall at a minimum provide the following information:

1. A description of the horizontal and vertical extent of any immiscible or dissolved plume(s) originating from the Facility;

2. The horizontal and vertical direction of contamination movement;

3. The velocity of ground water;

4. The horizontal and vertical concentration profiles of all constituents of potential concern (COPCs) in the ground water that are measured by EPA approved procedures;

5. A minimum of two complete COPCs analyses are required in all wells;

6. An evaluation of factors influencing the plume movement; and

7. An extrapolation of future contaminant movement.

The Respondent shall document the procedures used in making the above determinations (e.g., well design, well construction, geophysics, modeling, etc.).

2. Soil Contamination

The Respondent shall conduct an investigation to characterize the nature and extent of any contamination of the soil and rock units above the water table. The investigation shall provide the following information:

1. A description of the vertical and horizontal extent of contamination both onsite and off-site;

2. A description of contaminant and soil chemical properties within the contaminant source area and plume. This includes contaminant solubility, speciation, adsorption, leachability, exchange capacity, biodegradability, hydrolysis, photolysis, oxidation and other factors that might affect contaminant migration and transformation;

3. Specific soil properties and contaminant concentrations as proposed by Respondent and approved by EPA to include at a minimum;

1. USCS soil classification;

2. Soil profile, including ASTM classification of soils;

3. bulk density of soil;

4. soil pH;

5. particle size distribution;

6. moisture content;

7. storage capacity;

8. mineral content;

9. soil conductivity; and

10. concentration of constituents of potential concern at the site.

4. The direction of contaminant movement;

5. An extrapolation of future contaminant movement;

6. The Respondent shall implement a soil boring investigation to determine the extent of soil contamination at the Facility. Soil gas monitoring will be performed during drilling of all borings. Laboratory analysis of borings for contaminants listed in C.2.c.10 of the above section will be performed on soils at depths where either visual contamination is evident, or soil gas concentrations indicate contamination. All boreholes shall be properly abandoned. Disposal of all drilled soils will conform to all applicable State and Federal regulations;

7. Off-site soil contaminant plumes shall be defined using soil borings, soil gas monitoring, laboratory analyses, and closure of boreholes as described immediately above;

8. A characterization of the physical and chemical nature of soils and contaminants in the following areas:

1. Ditches and run-off accumulation areas at or near the SWMUs, AOCs, and/or Facility property boundaries;

2. All contaminated soil storage areas and waste piles;

3. Railcar unloading areas;

4. Truck unloading areas; and

5. Any other areas of concern.

9. Maps of all areas included in the soil investigation which are at an appropriate scale to represent the site.

3. Surface Water and Sediment Contamination

The Respondent shall conduct a surface water and sediment investigation to characterize contamination resulting from releases at the Facility.

The investigation shall include, but not be limited to, the following information:

1. A description of the horizontal and vertical extent of any immiscible or dissolved plume(s) originating from the Facility, and the extent of contamination in underlying sediments;

2. The horizontal and vertical direction of contaminant movement;

3. The contaminant velocity;

4. An evaluation of the physical, biological and chemical factors influencing contaminant movement;

5. An extrapolation of future contaminant movement;

6. The surface water and sediment investigation must include the following to ensure adequate assessment of contaminants at or near the Facility:

1. Samples of any ponded water bodies inside the Facility at or near a SWMU or AOC and immediately outside the Facility boundary near any SWMU or AOC;

2. Samples from drainage ditches, culverts, etc., which accept water from areas nearby any SWMUs or AOCs and drain to wetland areas;

3. Samples from wetland area at or near the Facility property boundaries and near a SWMU or AOC;

4. Samples from wetland areas, if it is determined that contaminated constituents may have reached these areas;

5. Analysis of samples for general water quality parameters, and should at minimum, include temperature, pH, dissolved oxygen (DO), conductivity, biochemical oxygen demand (BOD), chemical oxygen demand (COD), total suspended solids (TSS), total dissolved solids (TDS), total organic carbon (TOC), and nutrients; and

6. (6) Analysis of samples for constituents related to past and present Facility activities.

7. Maps for all areas included in the surface water and sediment investigation which are on a scale of appropriate to the size of the area.

The Respondent shall document the procedures used in making the above determinations.

4. Monitoring Wastewater Discharge

Respondent shall monitor the treated wastewater discharged from the Facility as required by Respondent’s NPDES permit. Respondent shall use accepted protocols for sampling and laboratory analyses, a description of which shall be submitted to the State and EPA for review with the RFI Workplan.

5. Wetlands Monitoring

Respondent shall investigate wetland areas when identified as potentially impacted by the Facility. Respondent shall determine if contamination has reached such wetland areas with a sampling and analysis plan designed to characterize the physical and chemical nature of surface water, sediments, soils, and contaminants.

4. Potential Receptors

The Respondent shall collect the information necessary to describe the human populations and environmental systems that are susceptible to contaminant exposure from the Facility. The following characteristics shall be identified:

1. Local uses and possible future uses of ground water:

1. Type of use (e.g., drinking water source: municipal or residential, agricultural, domestic/non-potable, and industrial) for each aquifer beneath the Facility.

2. Local uses and possible future uses of surface waters draining from the Facility:

1. Domestic and municipal (e.g. potable and lawn/gardening watering);

2. Recreational (e.g. swimming, fishing);

3. Agricultural;

4. Industrial; and

5. Environmental (e.g. fish and wildlife propagation).

3. Human use of or access to the Facility and adjacent lands, including but not limited to:

1. Facility operations;

2. Recreation;

3. Hunting;

4. Residential;

5. Commercial;

6. Zoning; and

7. Relationship between population locations and prevailing wind direction.

4. A description of the biota in surface water bodies on, adjacent to, or affected by the Facility.

5. A description of the ecology overlying and adjacent to the Facility.

6. A description of any endangered or threatened species near the Facility.

B.4. Task IV - Human Health and Ecological Risk Assessment

Sixty (60) days after the RFI Report is approved, the Respondent shall submit to EPA for review and approval a screening risk assessment or, if necessary, a baseline risk assessment for the potential human health and environmental risks posed by the site in the absence of any remedial action. For human health risks this effort will involve the following components: 1) contaminant identification; 2) exposure assessment; 3) toxicity assessment; and 4) risk characterization. For ecological risks the effort will include the following components: 1) problem formulation; 2) exposure assessment; 3) ecological effects assessment; and 4) risk characterization.

1. Human Health Risk Assessment

1. Contaminant Identification

The Respondent shall review available information on the hazardous substances present at the site and identify the major contaminants of concern. Contaminants of concern should be selected based on their intrinsic toxicological properties, because they are present above background, or risk-based screening levels, and/or because they are currently in, or potentially may migrate into, critical exposure pathways.

2. Exposure Assessment

The Respondent shall identify actual or potential exposure pathways, characterize potentially exposed receptors and evaluate the actual or potential extent of exposure.

3. Toxicity Assessment

The Respondent shall provide a toxicity assessment of those chemicals found to be of concern during site investigation activities. This will involve an assessment of the types of adverse health effects associated with chemical exposures, the relationships between magnitude of exposures, the relationships between magnitude of exposures and adverse effects, and the related uncertainties for contaminant toxicity.

4. Risk Characterization

The Respondent shall integrate information developed during the exposure and toxicity assessments to characterize the current or potential risk to human health posed by the site. This characterization should identify the potential for adverse health effects for the chemicals of concern and identify any uncertainties associated with contaminant(s), toxicity(ies), and/or exposure assumptions.

2. Ecological Risk Assessment

1. Problem Formulation

The Respondent shall perform problem formulation to characterize relevant ecological information about the site, identify contaminants and receptors likely to be present and identify potential effects that may occur. The outcome of the problem formulation component will be a site specific conceptual model describing pathways for contaminants, receptors of concern, expected linkages between site-related contaminants and ecological receptors that will be evaluated and effects that may be expected. Assessment endpoints and measurement endpoints will be identified as well as the hypotheses and objectives that will be evaluated.

2. Exposure Assessment

The Respondent shall perform an exposure assessment to document the release(s), migration and fate of contaminants and identify contaminants of concern. Representative biological receptors and their important habitats will be identified. The magnitude and the extent of exposure of contaminants of concern to receptors of concern will be documented.

3. Ecological Effects Assessment

The Respondent shall perform an ecological effects assessment including compilation of information on past studies of the toxicity of contaminants of concern to organisms of concern for the site and will conduct site specific studies to document effects (e.g., toxicity testing, community or population measurements, tissue residue analyses, and/or other biological effects measurements).

4. Ecological Risk Characterization

The Respondent shall perform ecological risk characterization by comparing exposure and effects information to assess the potential or actual effects at or near the site. Uncertainties in the ecological risk assessment process will be identified in this stage. This ecological risk characterization step will also be used to develop recommendations for ecologically protective clean-up levels, to evaluate any proposed remedial actions for their ability to reduce risk, and to identify further monitoring to document remedy effectiveness.

B.5. Task V - Investigation Analysis

In conjunction with the submittal of the Risk Assessment Report, the Respondent shall submit an Investigation Analysis to support the selection of Protection Standards for the Facility. The Analysis shall describe the extent of contamination (qualitative/quantitative) in relation to background levels indicative for the area around the Facility, and shall include the following information:

1. Protection Standards

1. Ground Water Protection Standards

For regulated units, the Respondent shall provide information including, but not limited to, the items listed below, which are necessary to support the EPA's selection/development of Ground Water Protection Standards for all of the Appendix IX constituents found in the ground water during the Facility Investigation (Task III). The Ground Water Protection Standards shall consist of:

1. For any constituents for which an MCL has been promulgated under the Safe Drinking Water Act, the MCL value; or

2. The background level of that constituent in the ground water; or

3. Those level of constituents which are demonstrated as being protective of human health and the environment.

2. Other Relevant Protection Standards

The Respondent shall identify, in the Investigation Analysis, all relevant and applicable standards for the protection of human health and the environment (e.g. National Ambient Air Quality Standards, Federally approved state water quality standards, etc.).

B.6. Task VI - Treatability Studies

The Respondent shall complete a Treatability Studies (TS) Program if so directed by EPA. Treatability studies are performed to determine the applicability of corrective measure technologies to conditions and problems at or resulting from the Facility. In addition, if applicable, testing results and operating conditions will be used in the detailed design of the selected remedial technology. Where it is determined by EPA that treatability testing is required, the Respondent shall complete the activities described in this Task.

1. Determine Candidate Technologies

The Respondent will identify candidate technologies for a treatability studies program in the Preliminary Report: Description of Current Conditions (Task I). Additional treatability studies may also be identified during the RFI/CMS process. Treatability Studies will include the following evaluations: (1) installation and operation of a system designed to recover and control migration of hazardous waste and constituents in ground water; (2) installation and operation of a system designed to recover and control migration of hazardous waste and constituents in soil; (3) installation and operation of a system designed to recover and control migration of hazardous waste and constituents in surface water; (4) installation and operation of a system designed to control migration of hazardous waste and constituents in air; and (5) any additional candidate technologies for a treatability studies program. The listing of candidate technologies will cover the range of technologies required for alternatives analysis. The specific data requirements for the testing program will be determined and refined during the RFI and CMS. The treatability study(ies) shall include the following:

1. Literature Survey

The Respondent will conduct a literature survey to gather information on performance, relative costs, applicability, removal efficiencies, operation and maintenance (O&M) requirements, and implementability of candidate technologies. If practical candidate technologies have not been sufficiently demonstrated, or cannot be adequately evaluated for this site on the basis of available information, treatability testing will be conducted.

2. Evaluate Treatability Studies

Once a decision has been made to perform treatability studies, the Respondent and EPA will decide on the type of treatability testing to use (e.g., bench versus pilot). Because of the time required to design, fabricate, and install pilot scale equipment as well as perform testing for various operating conditions, the decision to perform pilot testing should be made as early in the process as possible to ensure that results are integrated into the evaluation of corrective measure alternatives within the CMS.

2. Implementation of Treatability Studies

Where a TS Program is conducted, the deliverables that are required include a work plan, a sampling and analysis plan, and a final treatability evaluation report.

1. Treatability Testing Workplan

1. No later than thirty (30) days after receipt of written direction from EPA, Respondent shall submit to EPA a TS Workplan, for EPA review, modification, and approval.

2. The TS Workplan shall describe the site background, remedial technology(ies) to be tested, test objectives, experimental procedures, treatability conditions to be tested, measurements of performance, analytical methods, data management and analysis, health and safety, residual waste management and schedule (e.g., testing, deliverables, etc.). The data quality objectives (DQO) for treatability testing should be documented as well. If pilot scale treatability testing is to be performed, the pilot-scale work plan will describe pilot plant installation and start-up, pilot plant operation and maintenance procedures, operating conditions to be tested, a sampling plan to determine pilot plant performance, and a detailed health and safety plan. If testing is to be performed off-site, permitting requirements will be addressed.

2. Sampling and Analysis Plan (SAP)

1. If the original RFI Workplan is not adequate for defining the activities to be performed during the TS program, the TS Workplan shall include a treatability study SAP, or amendment to the original RFI Workplan.

2. Respondent shall submit the SAP as an element of the Draft TS Workplan.

3. Treatability Study

1. The Respondent shall complete TS activities according to the schedule described in the Workplan, and submit to EPA a Draft TS Report for review and approval by EPA.

2. No later than thirty (30) days after receipt of EPA's comments on the Draft TS Report, Respondent shall submit a Final TS Report which addresses all of EPA's comments to the satisfaction of EPA.

3. The report will evaluate each technology's effectiveness, implementability, cost and actual results as compared with predicted results. The report will also evaluate full scale application of the technology, including a sensitivity analysis identifying the key parameters affecting full-scale operation.

B.7. Task VII - Progress Reports

The Respondent shall at a minimum provide the State and EPA with signed, quarterly RFI progress reports containing:

1. A description and estimate of the percentage of the RFI completed;

2. Summaries of all findings;

3. Summaries of all changes made in the RFI during the reporting period;

4. Summaries of all contacts with representatives of the local community, public interest groups or the State government during the reporting period;

5. Summaries of all problems or potential problems encountered during the reporting period;

6. Actions being taken to rectify problems;

7. Changes in contact personnel during the reporting period;

8. Projected work for the next reporting period; and

9. Copies of daily reports, inspection reports, laboratory/monitoring data, etc.

3. Facility Submission Summary

A summary of the activities and reporting requirements contained in the RFI Scope of Work is presented below: